U.S. Court of Appeals for the First Circuit

The First Circuit affirmed summary judgment for the mortgage servicer and its successor, concluding that the borrower was not entitled to debt forgiveness because he did not satisfy the agreement’s payment conditions and the evidence did not show that those conditions were waived.

The First Circuit affirmed the grant of coram nobis relief, concluding that Morillo adequately explained her delay, received constitutionally deficient advice that understated the certain immigration consequences of her plea, and showed a reasonable probability that she would have gone to trial with correct advice.

The court held that the district court misinterpreted the drug-guideline provision governing minor-role adjustments by treating possession of more than user-level quantities and employment as part of an organization’s business model as categorical bars.

The court denied the petition for review, concluding that substantial evidence supports the agency’s findings that Alvarado-Hernandez did not establish past persecution or an objectively reasonable fear of future persecution.

The court affirmed dismissal of Alawieh’s amended habeas petition for lack of jurisdiction. It held that the INA’s narrow habeas exception permits review of whether an expedited-removal order was issued and relates to the petitioner, not review of the order’s validity based on an asserted defect in the officers’…

The court affirmed dismissal of the original failure-to-warn complaint because Amgen could not unilaterally secure a different label before FDA approval, and the FDA had considered and rejected the type of warning Warner proposed.

The First Circuit held that the Maine lobster-industry plaintiffs failed to state defamation claims because the challenged statements addressed a large industry and did not make particular reference to the plaintiffs.

The First Circuit affirmed Monteiro’s conviction for conspiracy to distribute cocaine and his 69-month sentence. It found no reversible error in the challenged officer testimony or the admission of evidence concerning Monteiro’s prior Haiti-related drug activity, and concluded that the trial evidence sufficed to…

The court dismissed the service providers’ petitions at their request, dismissed as moot portions of the state petitioners’ challenges, and dismissed the states’ constitutional challenge for failure to satisfy the Communications Act’s exhaustion requirement.

The court dismissed the service providers’ petitions at their request, dismissed as moot portions of the state petitioners’ challenges affected by the FCC’s 2025 order, and dismissed the states’ constitutional challenge for failure to satisfy the statutory exhaustion requirement.

The First Circuit affirmed confirmation of an arbitration award requiring Harvard to include psychology doctoral students performing lab-based research in the bargaining unit. It held that the grievance was arbitrable as a dispute over interpreting the existing collective bargaining agreement, that the arbitrator’s…

The court affirmed summary judgment on the Students’ RICO claim because the record did not establish closed-ended continuity: the alleged conduct did not extend over a substantial period, and the alleged misrepresentations were not shown to be false when made.

The court granted the defendants’ motion to stay the district court’s second enforcement order pending appeal. It concluded that the order likely modified the preliminary injunction by resolving a new, disputed contract-interpretation issue, making appellate jurisdiction likely, and that the district court likely…

The First Circuit affirmed summary judgment confirming an arbitration award that required Harvard to include psychology doctoral students conducting lab-based research in the bargaining unit.

The court held that Rhode Island waived Eleventh Amendment immunity in federal court for discrimination claims under RICRA. The Rhode Island Supreme Court had determined that RICRA claims are tort actions covered by the State Tort Claims Act, and its earlier interpretation of that Act established a waiver broad enough…

The court did not decide whether Rhode Island waived Eleventh Amendment immunity for claims under the Rhode Island Civil Rights Act. Because the state-law question whether those claims are “actions of tort” under the State Tort Claims Act could determine the immunity issue and lacked controlling Rhode Island…

The First Circuit affirmed Parsons’s drug-conspiracy and possession convictions, concluding that any error in admitting an officer’s opinion identifying Parsons as a user of a drug stash house was harmless in light of the extensive independent evidence.

The First Circuit affirmed the district court’s classification of the trustee’s $8.5 billion proof of claim as a Class 64 Section 510(b) subordinated claim, holding that the claim seeks damages arising from the purchase of PREPA revenue bonds and that the Board’s motion to enforce the plan was timely and properly…

The court affirmed the classification of the Trustee’s $8.5 billion claim as a subordinated claim under the Commonwealth Plan. It held that the claim’s own allegations established a causal connection between the claimed damages and the purchase of PREPA bonds, that the constitutional-avoidance canon did not support a…

The court affirmed the order classifying the Trustee’s claim as subordinated under § 510(b), concluding that the claim’s own allegations connect the Commonwealth’s impairment of protections that induced the bond purchases to damages arising from those purchases.

The court affirmed the classification of the Trustee’s claim as a subordinated claim under § 510(b), concluding that the claim alleged damages causally connected to the purchase of the PREPA bonds because the allegedly impaired protections had induced that purchase.

The court affirmed the order classifying the Trustee’s $8.5 billion claim as a subordinated claim under Bankruptcy Code § 510(b). It held that the claim’s own allegations tied the Commonwealth’s impairment of bondholder protections to the purchase of PREPA bonds, and that neither the alleged post-purchase timing nor…

The court affirmed the order classifying the trustee’s claim as subordinated under § 510(b), concluding that the claim’s allegations connected the claimed damages to protections that induced bond purchases.

The court held that the class could pursue its claims in district court and that the Guidance unlawfully permits third-country removals without effective notice and a meaningful opportunity to raise applicable fear-based claims.

The First Circuit affirmed the denial of Berkey’s motion for a preliminary injunction against EPA’s Stop Order. Berkey did not substantiate that the silver in its filters was used only to protect the filters or that the silver was registered for that use, so it failed to show likely success on its claim that the…

The First Circuit affirmed Levasseur’s conviction under the federal felon-in-possession statute. It held that he failed to show error in the district court’s conclusion that his methamphetamine-possession felony placed him in a category that could be disarmed because of a special danger of firearm misuse; his…

The court granted HUD’s motion for a stay pending appeal after concluding that HUD had made a strong showing it was likely to succeed in arguing that the NOFO set-aside was not subject to notice-and-comment requirements under the cited statutory provision.

The court affirmed the defense verdict, rejecting the plaintiffs’ challenges to the district court’s handling of a jury question, its instructions concerning Civil Service decisions and First Amendment considerations, and its instruction on employer liability under Massachusetts law.

The First Circuit granted HUD’s motion for a stay pending appeal of the district court’s summary-judgment order. It concluded that HUD had made a strong showing that the funding set-aside was not a “bonus or other incentive[]” subject to notice-and-comment requirements and that, without a stay, HUD could not make…

The First Circuit affirmed Levasseur’s felon-in-possession conviction, concluding that he failed to show error in the district court’s rejection of his as-applied Second Amendment challenge.

The First Circuit affirmed the jury’s verdict for the City and other defendants on the plaintiffs’ discrimination, retaliation, and hostile-work-environment claims under Massachusetts law.

The court held that the district court did not abuse its discretion by refusing to close the civil trial or allow the parties to use pseudonyms at trial, given the presumptive public-access rules and Doe’s failure to overcome the strong presumption against pseudonymity.

The court held that the appellants showed a reasonable likelihood of success on their as-applied viewpoint-discrimination claim arising from sanctions for silently wearing “XX” wristbands at a high school soccer game, because the record showed neither harassment nor disruption and indicated that officials acted…

The First Circuit exercised collateral-order jurisdiction over the denial of trial closure and pseudonymity, then affirmed both rulings under abuse-of-discretion review. It concluded that the district court properly applied the presumption of public access and that Doe did not establish circumstances sufficient to…

The court affirmed the denial of McDonald’s § 2255 challenge to his firearm conviction because the invalid predicate instruction was harmless: the record left no grave doubt that the firearm offense was supported by valid, factually coextensive predicates.

The First Circuit held that the district court abused its discretion by dismissing Pena de la Cruz’s indictment with prejudice after he was deported, because the circumstances did not show a patent threat of unfairness or otherwise meet Rule 48(a)’s narrow standard.

The court affirmed Parsons’s drug-conspiracy and possession convictions because any error in admitting the detective’s opinion that Parsons used the apartment as a stash house was harmless in light of the other evidence.

The court affirmed dismissal of the claims against EOHHS and Kate Walsh, finding no demonstrated error, but vacated the disposition of the compensatory-damages claims against MART and Jerry McDonald and remanded because Linardon had demanded a jury and had not validly waived that right.

The court affirmed dismissal of the claims against EOHHS and Kate Walsh, finding no demonstrated error. It vacated the disposition of the compensatory-damages claims against MART and Jerry McDonald and remanded because Linardon had demanded a jury and the record did not show a valid waiver.

The First Circuit affirmed Parsons’s drug-conspiracy and possession-with-intent-to-distribute convictions and his 84-month sentence. It held that any error in admitting an agent’s opinion identifying Parsons as a user of a drug stash house was harmless, and that the evidence supported constructive possession of…